TOURO COLLEGE AND UNIVERSITY SYSTEM POLICY MANUAL

This policy applies to all members of the Touro community, including students, faculty,
and administrators as well as third-parties (including, but not limited to, vendors,
invitees, etc.). Discrimination or harassment of any kind in regards to a person's sex is not tolerated
at our institution. Information and/or training regarding this policy is available
to students, faculty, and staff. In addition, information about this policy will
be available on Touro College’s (“Touro”) website.

2.0 Purpose

All divisions of Touro seek to foster a collegial atmosphere where students are nurtured
and educated through close faculty-student relationships, student camaraderie, and
individualized attention. Discrimination or harassment of any kind is anathema to
Touro’s mission, history, and identity. Touro will resolve any identified discrimination
in a timely and effective manner, and will ensure that it does not recur.

Those believing that they have been harassed or discriminated against on the basis
of their sex, including sexual harassment, should immediately contact the Title IX
coordinator. When Touro has notice of the occurrence, Touro is compelled to take immediate
and effective corrective action reasonably calculated to stop the harassment, prevent
its recurrence, and as appropriate, remedy its effects.

3.0 Definitions

3.1 Discrimination and Harassment

Title IX, and its implementing regulations, prohibit discrimination based on sex,
including sexual harassment. The prohibition against discrimination extends to employment and third-parties. Sexual harassment is unwelcome conduct of a sexual nature and can include sexual advances,
request for sexual favors, and other verbal, non-verbal, or physical conduct. Environmental
harassment (sometimes referred to as hostile environment) is sexually harassing conduct
that is sufficiently severe, persistent or pervasive to limit an individual’s ability
to participate in or receive benefits, services, or opportunities at Touro. This
can include persistent comments or jokes about an individual’s, sex; verbal behavior,
including insults, remarks, epithets, or derogatory statements; nonverbal behavior,
including graffiti, inappropriate physical advances short of physical violence such
as repeated and unwanted touching; and assault, including physical violence or the
threat of physical violence.

3.2 Retaliation

Retaliation is any kind of reprisal, adverse action, or negative action taken against
an individual because he or she has: (1) complained about alleged discrimination or
harassment as defined above, (2) participated as a party or witness in an investigation
relating to such allegations, or (3) participated as a party or witness in a proceeding
regarding such allegations. Retaliation can occur contemporaneously during the complaint
process or subsequent to it, once the retaliator is aware of the recipient’s participation
in the process. Retaliation does not exist in the absence of an adverse action. An
individual is protected from retaliation even when the complaint at issue is ultimately
found to lack merit, as long as the complaint was made in good faith.

Touro does not allow, nor tolerate any conduct by any Touro community member that
may be regarded as retaliatory. Retaliation against any individual, whether said person
submitted a complaint through the method described below in section 5.22 below, or
for any other reason will not be tolerated.

3.3 Title IX Coordinator

The Title IX Coordinator or his designee (“Title IX Coordinator”) is trained and knowledgeable
about enforcement, compliance, communication, and implementation of Touro’s anti-harassment
and anti-discrimination policy.

Touro has independent obligations to report or investigate potential misconduct,
even if a complainant does not wish to initiate an official process. Therefore, absolute
confidentiality cannot be promised with respect to a complaint of discrimination,
harassment, sexual harassment, or retaliation received either through Touro’s compliance
hotline or otherwise. The phone number for the Touro hotline is 212-463-0400 x5330.

Touro wishes, however, to create an environment in which legitimate complaints are
encouraged, while also protecting the privacy of all involved in an investigation.
Complaints about violations of these policies will therefore be handled in strict
confidence, with facts made available only to those who need to know in order for
Touro to promptly and thoroughly investigate and resolve the matter.

5.0 Procedures & Implementation

5.1 Duty to Report Violations

Any member of the Touro community including students, faculty, employees, and third-parties
have a duty to report violations of this policy where individuals know, or should
know, of accusations or actions which violate Touro Policy and will notify the Touro
Title IX Coordinator of such violations promptly.

All members of the Touro community are required to cooperate fully with any investigations
of discrimination or harassment. A faculty member, staff member, or student who has
relevant information and refuses to cooperate with an ongoing investigation will be
subject to disciplinary action for, among other things, violations of the Touro College
Code of Conduct and/or insubordination. Likewise, all Touro employees are required
to ensure that complaints about discrimination, harassment, or retaliation are directed
to the appropriate administrative office for evaluation and investigation. Touro is
committed to conducting an inquiry that is thorough, prompt and impartial.

Complaints should be filed as soon as possible after the date of the alleged misconduct,
and a written complaint is preferable.

A complaint, which must be submitted within the later of the following two dates:(a)
thirty (30) days after the alleged misconduct; or, (b) the end of the semester in
which the alleged incident occurred. A complaint should include the following information:

b) Name of the person against whom the complaint was made, including job title
or student status, if known.

c) The protected status that is the basis for the alleged discrimination, harassment,
or retaliation based on the complainant’s gender.

d) A clear statement of the facts that constitute the alleged discrimination,
harassment, or retaliation, including dates on which the acts were committed and any
information to identify witnesses.

e) Complainant should include the term and year of his/her most recent active
employment, academic, or student status within the university.

f) A student who is seeking admission to Touro should include the term and year
in which he/she sought admission to the university.

g) The full name, address, and telephone number of complainant’s advisor or supervisor,
if any.

h) The specific harm that resulted from the alleged act and the remedy sought.

i) The complainant’s signature and the date on which the complaint was submitted.

While prompt reporting is expected, complaints older than 30 days will be processed.
However, if more than 365 days have elapsed since the day of the complaint, the complaint
may not be processed. Every effort is made to conduct a thorough and speedy investigation.
Several factors may impact Touro’s ability to conduct a prompt investigation, including,
but not limited to: the Complainant’s accessibility or unresponsiveness, witness availability
or unresponsiveness, the number of witnesses, the timing of the investigation (i.e.
if an investigation is being conducted at a time when students are taking final exams
or on recess), etc.

5.23 Intake Interview

After receipt of a complaint, the Title IX Coordinator or his/her designee will meet
with the complainant as soon as possible, usually within one week, but not later than
thirty (30) days after receipt. The complainant must make himself/herself available
to meet.

The meeting will be an intake interview where the Title IX Coordinator or his/her
designee will inform the complainant about the investigation procedure and timeline.
The complainant may sign a formal complaint form at that time (under the above guidelines)
if he/she has not already done so. A complaint will proceed even in the absence of
a signed written complaint.

5.24 Complaints about Students, Faculty, Other Employees or Third Parties

Upon receipt of a complaint, the Title IX Coordinator or his/her designee, shall investigate
the circumstances of the complaint. This investigation will include documented interviews
of the complainant, the person against whom the complaint is written, and witnesses
with relevant knowledge, if any. Further, the investigation will include a review
of relevant documents and any other evidence.

The Title IX Coordinator shall have thirty (30) days from the intake interview to
complete the investigation of the event in question. Such thirty (30) days may be
extended in the event that one of the following occurs: · Availability or unavailability of a witness or relevant/material documents; · Recalcitrance of a witness and/or any necessary party; · Delay or other uncooperative actions of any necessary party; · Numerosity of witnesses; · Holidays and vacation periods; · Any other unforeseeable events/circumstances.

Generally speaking an investigation will take less than 60 calendar days following
receipt of the complaint. This may not be practicable in every investigation and
may vary depending on the complexity of the investigation and the severity and extent
of the harassment.. The Title IX Coordinator shall report the findings of the investigation
to a designated, impartial Fact Finder. The Fact Finder shall endeavor to issue a
determination within fifteen day after receipt of the investigation file to determine
and detail: (a) whether there is probable cause to believe discrimination occurred
with respect to each allegation in the complaint, (b) a description of actions taken,
if any, to prevent similar problems from occurring in the future, and (c) the proposed
resolution of the complaint.

5.25 Preponderance of the Evidence

The greater weight of evidence in an investigation meaning that one party’s evidence
outweighs the evidence of the other.

5.26 Notice of Determination and Further Action

Both the complainant, the party who filed the complaint or the alleged target of the
sexual harassment, and the respondent, the accused, shall be informed of the fact
finder’s decision within ten days of the conclusion of the fact finder’s deliberation.
Please refer to Section 4.0 for the policies regarding the confidentiality of this
determination.

At the time of the receipt of this notice both parties will be informed of any actions
or precautions that will be taken in response to the decision. Questions concerning
these further actions should be addressed to the Title IX Coordinator Kathy Lowe (see
Section 3.3 for contact information) or the appropriate office as required by the
fact finder’s decision.

5.3 Grade Appeals

Touro has a grade appeal process which is not circumvented by this policy. This procedure
is not a substitute for a grade appeal. A grade appeal may be suspended until a determination
has been made by the fact finder.

5.4 Discipline

Employees, faculty and students who violate Touro’s policies may be subject to disciplinary
action. Individuals who retaliate against someone who files a complaint, or against
a witness, representative, or advocate for a complainant, will be subject to further
disciplinary action.

Consistent with this Policy Touro will take prompt effective action to resolve any
identified discrimination, and take steps to avoid a reoccurrence.

5.5 Retaliation

Touro does not allow, nor tolerate any conduct by any Touro community member that
may be regarded as retaliatory. Retaliation against any individual, whether said person
submitted a complaint through the method described above in section 5.22 or for any
other reason will not be tolerated.

5.6 Availability of Counseling

As required under Title IX Touro College through its investigations and/or Title IX
Compliance officer will offer its internal counseling services to any complainant
who has begun the complaint process. It is ultimately complainant’s decision of whether
or not to accept the counseling service offered by Touro College. .

6.0 External Reporting

Members of the Touro community are always subject to local, state, and federal laws,
and nothing in these procedures is intended to limit or postpone the right of an individual
to file a complaint or charge with appropriate federal, state, or local departments
or agencies.

Among other options, students may contact the Office for Civil Rights of the U.S.
Department of Education for inquiries concerning the application of Title IX as well
as the implementation of its regulations. The Office for Civil Rights can be contacted
using the following information:

34 CFR 106.8 and 106.9 Revised Sexual Harassment Guidance: Harassment of Students By School Employees, Other
Students, or Third Parties, dated January 19, 2001 “Dear Colleague Letter” from the Assistant Secretary, U.S. Department of Education,
Office of Civil Rights, dated April 4, 2011.